The GOGP is in
the process of updating its fair-housing research and analysis, because
you just never know when you are going to need it!

Many claims are falsely made that the Conciliation Agreement requires
the rebuilding of 569 Public Housing units in the City of Galveston,
but those who are trying to sell this false assertion always fail to
mention that the Conciliation Agreement requires that any new Public
Housing units, or even project-based vouchers, in the City, MUST
Affirmatively Further Fair Housing (AFFH).

Now that all of the 2010 census data is available, it is time to
re-test the hypothesis, “Can additional Public Housing be built in the
City of Galveston and still Affirmatively Further Fair Housing;
as required by the Conciliation Agreement (CA) and the Fair Housing Act
(FHA)?”

Fair housing revolves around one primary factor: LOCATION.

In other words, it doesn’t really matter WHAT is built, e.g. scattered
sites, high rises, mixed-income, rehabbed units, or Cold-War-Era
barracks; it matters WHERE it is built.

How are acceptable locations chosen?

In their Fair Housing Planning Guide, HUD says that a regional approach
should be used to achieve fair housing, and many cases, such as
Thompson v HUD and Walker v HUD, had remedies that required a regional
or metropolitan approach. Selecting actual building sites moves the
process from the regional to the city and finally to the census tract
level.

There is no one “right answer” or specific regulation to point to on
how to select locations, but Professor John A. Powell developed a
three-part fourteen-point scoring system that was used in the remedy to
Thompson v. HUD, and his method is now in widespread use, and Professor
Kirk McClure has recently developed an opportunity index for HUD that
is designed to be used by public housing authorities (PHAs) to help them
select the best locations for portable voucher holders in order to
increase their opportunities to escape from a life of intergenerational
poverty.

The HUD-commissioned McClure index should at least meet the minimum
requirements for the proper site selection of building sites for “hard
units”, since their criteria should be even more rigorous considering
the fact that they can’t be moved after they are built. Unlike a poor
choice of neighborhood made by a portable voucher holder, who can move
after discovering a problem, a housing authority will have to live with
its mistakes in choosing the locations for hard units for decades.

Professor McClure’s index has many similarities to Professor Powell’s.
Both are the products of years of research and appeal to a basic common
sense approach.

POVERTY:
THE primary mandate of the Fair Housing Act is to de-concentrate
poverty, however, some continue to ignore this fact and argue that
Public Housing should be built where the greatest concentration of the
poor exists which only serves to further concentrate poverty. Anything that increases the
concentration of poverty violates the FHA.

Therefore, the most critical metric used in testing the proposed
locations for additional Public Housing units, to see if the locations
will AFFH, is the level of poverty, i.e. the percentage of individuals
living below the federal poverty level. Several other metrics can also
be used to support the selection process, but many have strong
correlations to the level of poverty (e.g. vacant housing rates, crime
rates,
etc.). Powell uses a relative ranking system to find the lowest poverty
areas within the region, while McClure uses the fixed definition that
the level of poverty must be less than 10% to be acceptable.

Both of these fair-housing experts work primarily at the census tract level, but
this analysis will use citywide demographics to focus on “the big
picture”, and leave the census tract details to the secondary analysis
once it is determined which cities will AFFH. For the purpose of this
analysis, Galveston County is the simplest way to define the region
that the GHA should use for Public Housing site selection.

The 2010 Census reveals that the City of Galveston continues to be the
poorest city in the County which immediately raises the question why
anyone wishing to comply with the requirements of the Fair Housing Act
would be pushing to build ADDITIONAL Public Housing in the poorest city
in the County that already contains ALL the Public Housing, for the entire
County, as well as 590 Low-Income Tax Credit (LITC) units, and
another 500-600 portable Section 8 voucher holders! How could this
possibly de-concentrate poverty? How could anyone want to build
additional units in this city when every other city in the County
offers an environment with less poverty than the City of Galveston?

One of the real surprises in the 2010 census data is that the loss of
Oleander Homes, Cedar Terrace and Magnolia Homes did NOT decrease
the concentration of poverty in this city! Poverty actually
increased in the City of Galveston from 22.3% in 2000 to 22.5% in 2010.
This fact alone should have caused HUD to order the dispersal of Public
Housing to other cities in an effort to reduce the already unacceptable
levels of poverty in the City. Adding more units can only make a bad
situation worse. However, HUD often allows "political considerations"
to trump the rights of the poor that they are supposed to
protect, as they ignore the requirements of the FHA.

City

%
of Individuals
Below Poverty Level(2010 Census)

Galveston

22.5%

La
Marque

17.5%

Texas
City

15.0%

Dickinson

13.4%

Santa
Fe

10.7%

League
City

6.0%

Friendswood

5.3%

At this early point in the process, it is already clear that the City
of Galveston fails as a location for additional Public Housing, due to
its high level of poverty, and the analysis could conclude
right here;
but there is much more to the story.

JOBS:
The second vitally important factor needed in any city for it to be
suitable for Public Housing is the availability of jobs. However, it is
not just the number of jobs; it is job growth that really counts.
Without job growth, how are those at the bottom of the economic ladder
going to find a way to enter the labor force?

The BLS only provides the following data base for cities with
populations greater than 25,000, so only four cities in the County can
be directly compared.

Galveston had 30,994 jobs in July 1995, but it is down to 20,828 in
June 2012, the latest available data. This means that not only did the
City have no job growth, over this period, it LOST 32.8% of the jobs it
used to have. How can Galveston possibly be a city that offers
opportunities to those struggling to enter the labor force when it has
a long history of job loss?

Texas City had 21,091 jobs in July 1995, but it is down to 19,266 in
June 2012, the latest available data. This means that not only did
Texas City have no job growth, over this period, it LOST 8.7% of the
jobs it used to have. How can Texas City possibly be a city that offers
opportunities to those struggling to enter the labor force when it has
a long history of job loss?

Friendswood had 14,320 jobs in July 1995, but it is up to 18,275 in
June 2012, the latest available data. This means that Friendswood had
job growth of 27.6%, over this same period. This is a city that does
offer opportunities to those struggling to enter the labor
force.

League City had 19,278 jobs in July 1995, and is up to 44,156 in June
2012, the latest available data. This means that League City had job
growth of 129.1%, over this same period. This is a city that does offer
opportunities to those struggling to enter the labor force.

City

Employment
Growth
July 1995-
June 2012(2012 BLS)

Galveston

-32.8%

Texas
City

-8.7%

Friendswood

+27.6%

League
City

+129.1%

Santa
Fe

?

Dickinson

?

La
Marque

?

How can anyone justify putting additional Public Housing units in the
City of Galveston, when Friendswood and League City offer so much
greater
employment opportunities?

EDUCATION:
The third vitally important factor needed in any city for it to be
suitable for Public Housing is an excellent public school system. There
are numerous studies showing the negative impact on all students in
schools with a high number of economically disadvantaged students.
Professor Powell uses this metric as part of his index.

"...school quality and the economic status of its student body have
been shown to have significant connections to student performance.
Higher poverty schools have been proven to negatively impact student
performance, regardless of the individual student’s economic status.
Also, teachers in higher poverty schools must spend more time to
address the additional needs of high poverty students and as a result
have less time to focus on teaching course work."
Remedial Phase Expert Report, by John A. Powell, In Thompson v. HUD,
August 19, 2005

City

%
Economically
Disadvantaged
Students(2012
Texas Tribune)

La
Marque

73.9%

Galveston

69.2%

Texas
City

62.0%

Dickinson

60.1%

Santa
Fe

32.8%

League
City

22.7%

Friendswood

6.2%

Why does anyone want to build Public Housing in Galveston when Santa
Fe, League City and Friendswood clearly offer superior schools for
children struggling to escape from poverty?

Summary:
The
examination of other metrics used by these two fair-housing experts confirms the
obvious message shown above by the three primary indicators presented
here; Santa Fe, League City and Friendswood are the cities where Public
Housing should be builtin order to AFFH and offer its residents the
best opportunity to escape from a life of intergenerational poverty.

The
City of Galveston suffers from the worst poverty, the worst job
opportunities, and has a public school system burdened with an
extremely high number of economically disadvantaged students making it
clearly the worst place to build Public Housing in the entire County.
Building in Galveston traps Public Housing residents in dead end lives
and it is shameful for government authorities and housing advocates to
even suggest that this should or must be done.

ENVIRONMENTAL:
Are there other reasons why additional Public Housing should not be
built in the City of Galveston?

Part of HUD’s mandatory “Environmental Review” is something that they
call “Environmental Justice”.

Environmental Justice:
Many
communities are exposed to disproportionate health and environmental
dangers because of their social, economic, or political position. The
impacts of agency projects must take account of these disproportionate
dangers and alleviate them when recognized. Executive Order 12898,
"Federal Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations," establishes that the agency
"shall make achieving environmental justice part of its mission by
identifying and addressing, as appropriate, disproportionately high and
adverse human health or environmental effects of its programs,
policies, and activities on minority populations and low-income
populations." More information on environmental justice is in the
Council on Environmental Quality publication, "Environmental Justice
Guidance under the National Environmental Policy Act".Link

The
GOGP review of the disproportionate “environmental dangers” that Public
Housing residents will be exposed to by building in the City of
Galveston are:

1. It will place residents in the Seaward
Hurricane Wind Risk Zone when the less risky Inland I and Inland II
Wind Risk Zones are available on the Mainland.

2. It will place residents in the highest risk hurricane flood zones
when far less risky areas are available on the Mainland.

3.
The three former housing project footprints north of Broadway, where the bulk
of the re-building is targeted, are in industrial areas that violate the
Environmental Justice regulations by placing poor minority residents:
within 1,000 feet of busy highways (Broadway, Harborside) and within
3,000 feet of railroads, subjecting them to high levels of noise; and
within 3,000 feet of numerous possible contamination sites, identified
by the EPA, subjecting them to higher potential health hazards than
more affluent residents.

Conclusion:
Given these facts,
why do so many powerful forces want to build additional Public Housing
in the City of Galveston? The simple answer is that it is the product
of a corrupt and sinister political bargain. To some degree it seeks to
confer political power on certain groups, but primarily it is all about
MONEY. That is the reason why HUD, the GLO, the GHA, the City of
Galveston, Texas Appleseed and Texas Low-Income Housing Information
Service (TXLIHIS) have all ignored the fair-housing mandate to move
Public Housing residents to areas that de-concentrate poverty and offer
them greater opportunities. Various politically-connected people make a lot of money by building Public Housing and providing services to it.

Are there any acceptable neighborhoods in the City of Galveston?

There
are four census tracts that satisfy McClure’s MINIMUM requirement that
they have poverty levels less than 10%, but all four are contained in a
city that has no job growth, a school system crippled with the
economically disadvantaged, and with the highest possible wind and
flood risks. So how could anyone justify building in those census
tracts when so many much better choices lie just a few miles north in
Santa Fe, League City and Friendswood?

To make matters worse,
the corrupt political forces demanding building in the City of
Galvestonalso want the largest developments built in three of the
worst census tracts in the city that will isolate poor minorities onto
reservations north of Broadway that are located in industrial areas
with potential environmental contamination hazards, busy highways and
other factors unsuitable for residential development. HUD rules say
that placing Public Housing in such areas violates the resident’s
environmental justice rights.

Why aren’t the Galveston Daily
News and the Houston Chronicle analyzing and reporting on the
demographic REQUIREMENTS of the Fair Housing Act? They have reported
many times that if 569 Public Housing units are not rebuilt, in the
City of Galveston, it will violate the FHA, but how do they know that?
They think that they know that, because they are repeating what the
“government authorities” and “fair housing groups” say all the time,
without checking the veracity of the claims themselves.

Neither newspaper has done a detailed analysis of what a PHA actually has to do to
satisfy the requirements of the FHA. Both of them obviously support
the rebuilding of Public Housing in this city, so repeating the mantra
that it must be done, in order to satisfy the FHA, must seem to be a good way
to frighten the local politicians into doing so.

This is what it looks like
when a newspaper actually examines the requirements of the Fair Housing
Act, and this was donein ultra liberal Portland, Oregon. To their surprise, they found violations of the FHA almost everywhere that they looked, and it didn't take a whole lot of digging.